Um... ICO copping out.
If the boot was on the OTHER foot, American authorities would be using "Long Arm" statutes to come down hard on any UK outfit breaching USA laws (what do you think all those extradition demands were about when noone had set foot on US soil, for starters?)
What this needs is someone to file a complaint with German privacy authorities as they take this shit seriously and don't pull "oh, it's all in another country so we can't do anything about it" bullshit, when the laws are clearly written so they DO have extraterritorial cover.
Biting the hand that feeds IT
